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Welcome to a Towing Vessel Conversation

Welcome to a Towing Vessel Conversation. USCG Sector Honolulu Prevention Department. Topics for discussion. TVBP (Past, Present and Future) UTV Exam Form UTV “C” School Subchapter M, NPRM Comments Public Meetings Overview Timeline. Towing Vessel Bridging Program. Past

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Welcome to a Towing Vessel Conversation

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  1. Welcome to a Towing Vessel Conversation USCG Sector Honolulu Prevention Department

  2. Topics for discussion • TVBP (Past, Present and Future) • UTV Exam Form • UTV “C” School • Subchapter M, NPRM • Comments • Public Meetings • Overview • Timeline

  3. Towing Vessel Bridging Program • Past • Coast Guard and Maritime Transportation Act of 2004 • Phase I, Summer 2009, Outreach, Education, Qualification, Industry Initiated Exams • Present • 62 Vessels, 23 decals (37%), 45 examined (73%) • Future • Phase II, ETA… Priority Based Exams, Continue Phase I, underway boardings, PSIX visibility for Priority Based Exam deficiencies • Decal expiration (3 year) • Phase III, COI issuance TVBP Homeport link

  4. Priority Based Exams Note – Deficiencies identified during priority based exams (not IIEs) will be publically available through PSIX

  5. UTV Exam Form • Changes from old form • New Requirement for UTVs guidebook • Changes to exam item locations/groupings • CEMS removed • Additional statuses on first page • Separate recommendations and deficiencies pages • New Instructions form

  6. UTV “C” School • Yorktown, VA • Paducah, KY • Exportable • http://www.uscg.mil/hq/cg5/TVNCOE/Courses.asp

  7. NPRM Subchapter M – Comments • Online or in writing • Comments and related material must be submitted to the online docket on or before December 9, 2011 • Identify comments by inserting Docket Number USCG-2006-24412 in the “docket ID” box • Federal eRulemaking Portal http://www.regulations.gov

  8. Subchapter M – Public Hearings • Dates and Locations • Tuesday, 18 Oct – Newport News, VA • Monday, 24 Oct – St. Louis, MO • Wednesday, 26 Oct – Kenner, LA • Wednesday, 16 Nov – Seattle, WA • Webcasts - http://www.towingvesselregs.us/ • http://www.uscg.mil/msib/docs/043_11_9-9-2011.pdf

  9. NPRM – Overview • Preamble • Public Participation and request for comments • Abbreviations • Background • Discussion of Proposed Rule & CEMS / Work rest • Incorporation by Reference • Regulatory Analysis

  10. Subchapter M – Parts • 136 – Certification • 137 – Vessel Compliance • 138 – Towing Safety Management System • 139 – Third-party Organizations • 140 – Operations • 141 – Lifesaving • 142 – Fire Protection • 143 – Machinery and Electrical Systems and Equipment • 144 – Construction and Arrangement

  11. Applicability • Applicability – All towing vessels (commercial, engaging or intending to engage in pulling, pushing, hauling along side or any combination thereof) • Exceptions • Less than 26 feet, unless towing barges carrying dangerous or hazardous materials • Assistance towing • Vessels towing recreational vessels for salvage • Vessels transporting or assisting navigation of recreational vessels within and between marinas and marina facilities within a limited geographic area • Workboats operating exclusively in a worksite • Seagoing towing vessels > 300 GRT • Vessels otherwise inspected that “may perform occasional towing” • Public vessels • Vessels that surrendered COI and is laid up, dismantled or otherwise out of service • Propulsion units used to propel or control direction of a barge (controlled from the barge, not normally manned, not used as independent vessel)

  12. Certification • All COIs issued by USCG (5 year validity) • Options for certification • Annual USCG inspection • Towing Safety Management System (TSMS) with use of approved 3rd parties • Specify option when applying for each COI (may be different for each vessel) • Drydock/Internal Structural Exam – twice in 5 years, no more than 36 months (for all vessels exposed to salt water more than 6 months per year)(once in 5 otherwise) • UWILD option available 46CFR137.335

  13. USCG Option • Owner/Operator schedules with OCMI • Annual inspection +/- 3 months of anniversary • Similar but less detailed than COI issue/renewal • May include any tests or inspections deemed necessary to evaluate seaworthiness • Deficiencies documented with timeframe on CG-835 • Periodic inspection (full) at +/- 3 months of 2nd or 3rd anniversary (takes place of annual)

  14. What is an approved 3rd party? • Organization approved by the USCG to carry out functions related to ensuring that TVs comply with the provisions of Sub M (audits, TSMS certificates, surveys, reports) • Must be independent of the owner, managing operator and vessels they will be acting as 3rd party for • Must meet all the requirements of 46CFR139 • Recognized classification societies (46CFR8) are prequalified 46CFR139.110

  15. TSMS Option • Obtain TSMS Certificate from 3rd approved party within 2 years of final rule (5 yrs expiration) • TSMS must meet requirements of 46 CFR138 • ISM is deemed in compliance 46CFR138.225 • Internal audits conducted annually +/- 3 months of TSMS certificate • External (3rd party) audits prior to TSMS certificate issuance and renewal • External management audit between 27th and 33rd month • External audit of each vessel during 5 year period (TSMS cert) • Annual External audits of vessel 137.205 • Notify USCG prior to conducting 3rd party audit • Submit results to USCG

  16. This chart shows the compliance timeline depicted in the proposed rule. The proposed rule phases-in the requirements to lessen the burden on the towing companies. After the final rule is issued, a company has two years to develop a TSMS if they utilize the TSMS option. The initial COI must be obtained within 4 years from the TSMS approval. Certain requirements for electrical and machinery systems, such as pilothouse alerter system and remote shutdown devices, were deferred until five years after the initial COI. Towing vessels moving oil or hazmat in bulk also have certain electrical and machinery requirements deferred until five years after the first COI.

  17. Some new parts • AED 140.435 • Health and Safety Plan 140.500 • Handheld VHF radio 140.715 • Survival Craft 141.305 • Life buoys 141.360 • Visual Distress Signals 141.375 • Line Throwing Appliance 141.385 • Flammable Storage 142.225 • Smoke alarms in berthing areas 142.335 • Heat detectors in galley (new vessels) 142.340 • Fireman’s outfit (>79 foot, oceans or coastwise, no fixed fire suppression) 142.345 • Fire axe 142.350 • Machinery and Electrical 143 • Alarms 143.245 • Pressure vessels (5ft3 15psi) 143.300 • Lighting 143.310 • Pilothouse alerter system 143.325 • Remote shutdowns 143.335 • Generator requirements 143.340 • Additional requirements for vessels that tow oil or hazmat in bulk 143.400 • Construction and arrangement 144

  18. Questions? • LT Javier Lopez • 808 522-8264 ext. 359 • MST1 Russ Strathern • 808 522-8264 ext. 235

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